Title:
Code:
Date:
Approved:
Professional Standards and Business Conduct -- Reporting of Fraud
1-100-015
7-15-91
JDM
Introduction
Sound business conduct requires that each employee, as a basic condition of employment, assume
responsibility for safeguarding and preserving the assets and resources of the University, particularly
those for which he or she is responsible. The following policy statements serve to remind us of that
basic commitment and responsibility.
1.
All revenues generated by the University, and all expenditures for goods and services, must be
recorded and accounted for within the financial accounting system of the institution.
2.
No false or artificial entries are to be made in the accounting records of the University for any
reason. Moreover, no payment on behalf of the University is to be approved or made with the
understanding that any part of such a payment is to be used for any purpose other than that
described by the documents supporting the payment.
3.
The use of University funds or assets for any personal, unlawful, or improper purpose is
prohibited.
4. The use of any University equipment, supplies, or facilities for a revenue generating activity
that benefits an individual employee is strictly prohibited without the express written approval
of the cognizant vice president and the Executive Vice President.
5.
No person in a supervisory or management position is to use the authority of that position to
assign an employee to perform nonemployment related tasks.
6. Managers have a responsibility to develop and implement controls to minimize opportunities
for fraud to occur.
Policy
In conjunction with the policy guidelines stated above, each University employee is further expected to
report any instance of suspected fraud to the Director of Internal Audit. If an instance of suspected
fraud is reported instead to a supervisor, chairperson, director, dean, vice president, or other
responsible person, that person is to report the instance to the Director of Internal Audit.
If presented with reasonable evidence of a suspected fraud, the Director of Internal Audit will conduct
an audit to determine if the reported suspicions of fraud are valid. The Director will also inform the
supervisor of any employee under investigation. If, based on the results of the audit, the Director has
reason to believe that fraudulent activities have occurred, he or she will report the findings to the
President, the Executive Vice President, the Financial Vice President and Treasurer, and the
Controller.
Any determination of fraudulent activities that may involve an amount of money over $50,000, or that
may prove a source of public embarrassment for Boston College, will be reported immediately by the
Financial Vice President and Treasurer to the Chairman of the Financial and Audit Committee of the
Board of Trustees.
All determinations of fraudulent activities will be reported semiannually by the Director of Internal
Audit to the Financial and Audit Committee. The Director will compile a report for the Committee's
review outlining the following information: (a) the amount of the fraud; (b) the individual(s) involved;
(c) how the fraud was identified; (d) how the fraud was perpetrated; (e) how the University chose to
deal with the perpetrator; and (f) the controls that have been implemented to prevent recurrence of the
fraud.
WWW: April 24, 1997